Tui Early Learners Ltd Privacy Statement

At Tui Early Learners Ltd we recognise the importance of privacy protection. We have created this Privacy Statement to demonstrate our commitment to you, your privacy and to secure and trustworthy Internet commerce.

Types of Personal Information we collect

Generally, the only personal information we collect is contact details of representatives of:

customers,

prospective customers,

partners, and

other individuals interested in receiving information from Tui Early Learners Ltd.

This includes details such as their names, addresses, telephone numbers and email addresses. We also record information concerning transactions that individuals make or wish to make with Tui Early Learners Ltd and as well as information concerning customer preferences and satisfaction with Tui Early Learners Ltd’s products and services.

Tui Early Learners Ltd’s Compliance Commitment

Generally, Tui Early Learners Ltd will only collect personal information when necessary to provide a specific service or function. This includes Tui Early Learners Ltd product and event information and software upgrade information.

Where practicable, when this personal information is collected it is done so directly from the individual, either by phone, over the Internet or in person. We may also collect personal information indirectly such as where one customer representative gives us details of another customer representative.

Collection of personal information

Tui Early Learners Ltd will take reasonable steps to ensure
that the individual is aware of:

Tui Early Learners Ltd’s identity and how to contact us,

their ability to gain access to their personal information,

the purposes for which the information is collected,

the organisations (or the types of organisations) to which Tui Early Learners Ltd usually discloses information of that kind,

any law that requires the particular information to be collected, and

the main consequences (if any) for the individual if all or part of the information is not provided.

If Tui Early Learners Ltd collects personal information about an individual from someone else, Tui Early Learners Ltd will take reasonable steps to ensure that the individual is or has been made aware of the matters listed above.

Use and Disclosure

Generally Tui Early Learners Ltd will only use and disclose personal information for the primary purpose for which it was collected. For example, personal information may be used to provide a specific service or function to individuals, to process requests and transactions, and to communicate marketing offers and information to individuals.

This may include providing personal information to external organisations or to our related companies where they are assisting us to provide a service or function. Where we do provide third parties with personal information, we have measures in place to ensure they do not use the personal information for any purpose other than providing the relevant service or function.

Tui Early Learners Ltd will only use or disclose personal information about an individual for a purpose other than the primary purpose (the secondary purpose) of collection if:

The secondary purpose is related to the primary purpose of collection; and

The individual would reasonably expect Tui Early Learners Ltd to use or disclose the information for the secondary purpose; or

The individual has consented to the use or disclosure; or

If the information is not sensitive information and the use of the information is for the secondary purpose of direct marketing: it is impracticable for Tui Early Learners Ltd to seek the individual’s consent before that particular use; and

Tui Early Learners Ltd will not charge the individual for requesting to not receive direct marketing communications; and

the individual has not made a request to Tui Early Learners Ltd not to receive direct marketing communications; and

in each direct marketing communication with the individual, Tui Early Learners Ltd directly advises the individual, or prominently displays a notice, that he or she may express their desire not to receive any further direct marketing communications; and

each written direct marketing communication by Tui Early Learners Ltd with the individual (up to and including the communication that involves the use) sets out Tui Early Learners Ltd’s business address and telephone number and, if the communication with the individual is made by fax, telex or other electronic means, a number or address at which Tui Early Learners Ltd can be directly contacted electronically; or

Tui Early Learners Ltd has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or

the use or disclosure is required or authorised by or under law; or

Tui Early Learners Ltd reasonably believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of an enforcement body:

the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;

the enforcement of laws relating to the confiscation of the proceeds of crime;

the protection of the public revenue;

the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct;

the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.

Data quality

Tui Early Learners Ltd will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. If you believe that the information held is inaccurate please do not hesitate to contact the Privacy Officer below.

Data Security

Tui Early Learners Ltd will take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. Tui Early Learners Ltd stores personal information in various secure electronic storage facilities and paper-based files.Tui Early Learners Ltd will also take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed.

Openness

Tui Early Learners Ltd policy on our management of personal information is set out in this document, as may be amended by Tui Early Learners Ltd from time to time. To ensure you have a copy of the most current version of Tui Early Learners Ltd’s privacy statement, please refer to Tui Early Learners Ltd’s website: http://www.professionaldevelopment.co.nz/tuiearlylearners/.

Access and Correction

If Tui Early Learners Ltd holds personal information about an individual, we will provide the individual with access to the information on request by the individual, except to the extent that:

in the case of personal information other than health information-providing access would pose a serious and imminent threat to the life or health of any individual; or

providing access would have an unreasonable impact upon the privacy of other individuals; or

the request for access is frivolous or vexatious; or

the information relates to existing or anticipated legal proceedings between the organisation and the individual, and the information would not be accessible by the process of discovery in those proceedings; or

providing access would reveal the intentions of Tui Early Learners Ltd in relation to negotiations with the individual in such a way as to prejudice those negotiations; or

providing access would be unlawful; or

denying access is required or authorised by or under law; or

providing access would be likely to prejudice

an investigation of possible unlawful activity; or

the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; or

the enforcement of laws relating to the confiscation of the proceeds of crime; or

the protection of the public revenue; or

the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or

the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders;by or on behalf of an enforcement body; or

an enforcement body performing a lawful security function asks Tui Early Learners Ltd not to provide access to the information on the basis that providing access would be likely to cause damage to the security of the country.

However, where providing access would reveal evaluative information generated within Tui Early Learners Ltd in connection with a commercially sensitive decision making process, Tui Early Learners Ltd may give the individual an explanation for the commercially sensitive decision rather than direct access to the information.

If Tui Early Learners Ltd is not required to provide the individual with access to the information because of one or more of the above paragraphs Tui Early Learners Ltd will, if reasonable, consider whether the use of mutually agreed intermediaries would allow sufficient access to meet the needs of both parties.

If Tui Early Learners Ltd charges for providing access to personal information, those charges:

will not be excessive; and

will not apply to lodging a request for access.

If Tui Early Learners Ltd holds personal information about an individual and the individual is able to establish that the information is not accurate, complete and up-to-date, Tui Early Learners Ltd will take reasonable steps to correct the information so that it is accurate, complete and up-to-date.

If the individual and Tui Early Learners Ltd disagree about whether the information is accurate, complete and up-to-date, and the individual asks Tui Early Learners Ltd to associate with the information a statement claiming that the information is not accurate, complete or up-to-date, Tui Early Learners Ltd will reasonable steps to do so.

Tui Early Learners Ltd is obliged to provide reasons for denial or refusal of access to correct personal information. If you would like to access any personal information held by Tui Early Learners Ltd about you, please do not hesitate to contact the Privacy Officer below.

Identifiers

Tui Early Learners Ltd does not use identifiers such as Tax File Numbers to identify individuals.

Anonymity

Where lawful and practicable, Tui Early Learners Ltd will provide individuals with the option of not identifying themselves when providing personal information.

Transborder Data Flows

Tui Early Learners Ltd may transfer personal information about an individual to someone (other than Tui Early Learners Ltd or the individual) who is in a foreign country only if:

Tui Early Learners Ltd reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information; or

the individual consents to the transfer; or

the transfer is necessary for the performance of a contract between the individual and Tui Early Learners Ltd, or for the implementation of pre-contractual measures taken in response to the individual’s request; or

the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between Tui Early Learners Ltd and a third party; or

all of the following apply:

the transfer is for the benefit of the individual;

it is impracticable to obtain the consent of the individual to that transfer;

if it were practicable to obtain such consent, the individual would be likely to give it; or

Tui Early Learners Ltd has taken reasonable steps to ensure that the information that it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with this Privacy Statement.

Sensitive Information

Generally Tui Early Learners Ltd does not collect sensitive information. In the event Tui Early Learners Ltd does wish to collect sensitive information however, we will not do so unless:

the individual has consented; or

the collection is required by law; or

the collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the individual whom the information concerns

is physically or legally incapable of giving consent to the collection;

physically cannot communicate consent to the collection; or

the collection is necessary for the establishment, exercise or defence of a legal or equitable claim.

Removal from Tui Early Learners Ltd Mailing Lists

Should you decide that you no longer wish to receive promotional and marketing material from Tui Early Learners Ltd, please advise as directed on the material you have been sent or via email, fax or letter being sure to include your name, address and contact details.

Complaints Management

Individuals are to direct all complaints to Tui Early Learners Ltd’s privacy officer.

To be removed from a distribution list:

Tui Early Learners Ltd requires this request to be advised in writing via email, letter or fax.

Tui Early Learners Ltd will notify all departments within Tui Early Learners Ltd to remove the individual from distribution lists.

Tui Early Learners Ltd will advise the individual in writing that this request has been actioned.

Access to Personal Information held by Tui Early Learners Ltd

When an individual requests access to their personal information, Tui Early Learners Ltd will:

take all reasonable endeavors to take action within 30 days of receipt of notification from the individual;

require individuals to provide written notification to access personal information held by Tui Early Learners Ltd;

evaluate the request for access to determine motivation for requesting access: e.g. is the request frivolous or vexatious?

For a valid request, Tui Early Learners Ltd’s privacy officer will:

inform all relevant departments that this individual has requested to access the information held;

consolidate all of the information;

discuss with the individual how they would like to view this information:

If personally, Tui Early Learners Ltd’s privacy officer and the individual will arrange a meeting time and place;

If via letter / photocopies, Tui Early Learners Ltd’s privacy officer will prepare and send these to the individual.

Enquiries

If you require any further information or confirmation about this Privacy Statement or if you are concerned that Tui Early Learners Ltd is not complying with its privacy obligations in respect of your personal information, please contact:

Protection and use of information collected on-line

Use and purpose of collected personal data

On our Web sites we only collect information relating to you with your permission. You may choose to reveal information to us if, for example, you register or complete a survey. Companies in the Tui Early Learners Ltd group may use the information internationally in connection with processing your inquiries and orders or to help improve our products and services. We would only share such information with third parties outside the Tui Early Learners Ltd group with your express permission or as required by law. It is used solely for the purposes described below.

Online security

Tui Early Learners Ltd supports secure online shopping using secure server technology, because we want your shopping experience to be simple and safe. There are state-of-the art security arrangements and facilities on Tui Early Learners Ltd sites to prevent security abuse. The secure server technology used on Tui Early Learners Ltd Store encrypts your personal financial information before it is transmitted over the Internet. This technology works best when the store site is viewed using a browser that supports secure server technology.

Privacy across the entire Tui Early Learners Ltd network

As a global company, Tui Early Learners Ltd operates a number of Web sites around the world. Any information that you submit to one of our sites in any one country or language may be sent electronically to a server for one of these sites in another country. As such, the information may be used, stored, or processed outside the country where it was recorded. We safeguard your privacy interests around the world by ensuring that the Tui Early Learners Ltd site adheres to our policies described in this statement.We bind our employees to observe your privacy and confidentiality rights.

Consent

By using our Web sites, you consent to the collection and use of the information as described here. If we decide to make changes to this privacy statement, we will post the changes on this page so that you will always know what information we collect, and how we use it.

What information do we collect on-line and why?

IP addresses

We may use your IP address to help diagnose problems, to administer our Web site, or to gather general demographic information.

Cookies

We use cookies to make your use of our online offering more enjoyable and to deliver personalised content. Cookies help us give you information that interests you, they save you having to reenter your password every time you visit our site, and help to keep track of your shopping cart. Cookies also allow us to better analyse our site traffic patterns so that we can improve our Web offering. We do not follow your browsing path outside of the Tui Early Learners Ltd site; Web partners that serve ads onto our Web site may also use their own cookies.

User registration

You may choose to fill out a registration form on our Web site with contact information. This information is used to send you requested information or products, to contact you with other product information, news, or promotions, and to learn more about our Web visitors.

E-mail addresses

If you give us your e-mail address, we may communicate with you via e-mail. However, we will not share your e-mail address with others outside the Tui Early Learners Ltd group of companies without your consent. You can choose not to receive e-mails at any time - for more details, read the Choice/Opt-out section below. Depending how your e-mail application is set up, information about you may be transmitted automatically when you send e-mail to Tui Early Learners Ltd.

Registration for third-party services at Tui Early Learners Ltd

At Tui Early Learners Ltd you can register for third party services. Those services are available through Tui Early Learners Ltd, but are provided by a third party, which is typically not affiliated with Tui Early Learners Ltd. When you sign up for one of these services, it may be necessary to transfer some of your Tui Early Learners Ltd.com registration information to this service provider. Also, if the service you chose requires your e-mail address to fulfill this service, we will also give your e-mail address to the service provider. This means we will pass your e-mail address to a service provider only in the event that you specifically asked for this service and the service cannot be provided without your e-mail address. For privacy practices and opt-out procedures of those service providers, refer to the individual privacy policy of the respective service provider.

"Send this to a friend" service

You can choose to forward information, a Web page, or link to someone else using our "Send this to a friend" e-mail service. In order to do that, you provide us with your e-mail address, as well as that of the recipient. This information is used only in the case of transmission errors and, of course, to let the recipient know who sent the e-mail. The information is not used for any other purpose.

Shopping

Our site includes order forms that you fill out to request information, products, and services. These forms collect your financial information, such as your banking details or credit card. We will only use this financial information that you submit solely for billing and payment purposes.

Online surveys

Occasionally we conduct online surveys. Our surveys may ask you for demographic information, such as postal codes or your industry sector. If the online survey collects contact data, we may use that data to send you further information only if we specifically asked for your permission in the survey. You are free to opt out of receiving future mailings at any time. For more details, read the Choice/opt-out section below.

Demographic and user profile data

We may use demographic or user profile data we collect to tailor your Web experience, showcase content that we think may interest you, and display information that matches your preferences. This data also gives us an insight into your needs and interests.

Links to other sites

Our site contains links to other sites. Tui Early Learners Ltd is not responsible for the privacy practices or the content of other Web sites. For more information, refer to the privacy policies of the respective site.

Choice / opt-out

Tui Early Learners Ltd gives you the choice to opt out at any time. You can opt-out of receiving communications from us whenever you like: now or at the point on our site where we request information from you.

Unsubscribe from Tui Early Learners Ltd newsletter

If you no longer wish to receive our free newsletter Tui Early Learners Ltd Newsletter, you can cancel your subscription at any time. Just send an e-mail message to deborah@tuiearlylearners.co.nz with “Unsubscribe” in the subject field.

Removal from our registration database

If you wish to be removed from the Tui Early Learners Ltd’s Web registration database, please contact:

Professional Development Limited Use of Information

Professional Development Limited reserve the right to access information on the website and in any database associated with the website for the purposes of testing and site support. At no time will Professional Development Limited submit details collected to any third party or use these details for contact and/or marketing without the permission of the website owner or client.